“Planning for In-Home Care”

by Rowan Report | Jul 24, 2025 | Advocacy, Home Health, Hospice, Partner News

FOR IMMEDIATE RELEASE

Contact: Elyssa Katz
571-281-0220
communications@allianceforcareathome.org

The Alliance’s CaringInfo Program Launches New “Planning for In-Home Care” Section

Rebrands to Align with Expansion to Serve Full Home-Based Care Continuum

ALEXANDRIA, VA and WASHINGTON, DC – CaringInfo.org, a program of the National Alliance for Care at Home (the Alliance), is expanding its resources with a new website section – “Planning for In-Home Care” – as well as a brand refresh to align with its growing audience. CaringInfo provides free resources to educate and empower patients and caregivers to make informed decisions about home, serious illness, and end-of-life care and services.

CaringInfo

While CaringInfo began with a focus on serious illness and end-of-life care and support, the program’s content is expanding to provide information and resources on the full spectrum of home-based care services. As a first step in this expansion, CaringInfo has launched “Planning for In-Home Care,” a new section on the website focused on the various types of care available at home.

Planning for In-Home Care

The new section covers essential topics including when in-home care is needed, preparing for in-home caregivers, who provides in-home care services, how to find a caregiver, and how to pay for in-home care.

“CaringInfo is a valuable resource used widely among hospice, palliative, and advance care planning experts and professionals as well as patients and families who need help and guidance.”

Dr. Steve Landers

CEO, The National Alliance for Care at Home

Landers, continued, “The launch of ‘Planning for In-Home Care’ marks an exciting step in the continued expansion of CaringInfo to provide resources and guidance on the full continuum of home-based care and to serve as a resource to all providers under the Alliance umbrella. Finding and navigating care at home can be difficult for patients and their loved ones, especially as it is often needed during life’s most vulnerable moments. These free, accessible resources help ensure everyone seeking home-based care can make informed decisions to get the support they need.”

Visual Update

The updated CaringInfo design is intended to remain familiar for return visitors who trust the site as their go-to source for making care decisions, while aligning with the Alliance’s core brand. This visual update indicates CaringInfo’s realignment to serve the full home-based care community, including home health, home care, Medicaid HCBS, palliative care, and hospice providers.

CaringInfo’s goal is that all people are making informed decisions about their care. In addition to easy-to-understand information about caregiving, advance care planning, and the types of care available to those who need it, CaringInfo also offers a complete library of annotated advance directive forms for all 50 states, plus Washington, DC and Puerto Rico. The full site is available in both English and Spanish.

Visit CaringInfo.org, which is free and available to all, to explore the full site as well as the new content.

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About the National Alliance for Care at Home

The National Alliance for Care at Home (the Alliance) is the leading authority in transforming care in the home. As an inclusive thought leader, advocate, educator, and convener, we serve as the unifying voice for providers and recipients of home care, home health, hospice, palliative care, and Medicaid home and community-based services throughout all stages of life. Learn more at www.AllianceForCareAtHome.org.

Alliance Statement on House Passage of Reconciliation Bill

by Rowan Report | Jul 3, 2025 | Advocacy, Breaking News, Partner News, Regulatory

FOR IMMEDIATE RELEASE

Contact: Elyssa Katz
571-281-0220
communications@allianceforcareathome.org

Medicaid Provisions Threaten Home and Community-Based Services for Millions of Vulnerable Americans

Alexandria, VA and Washington, DC, July 3, 2025. The National Alliance for Care at Home (the Alliance) issued the following statement today in response to the House’s passage of the “One Big Beautiful Bill Act,” also known as the Reconciliation bill, which now heads to President Trump’s desk for his signature.

“The Alliance is deeply troubled by the Medicaid provisions within the One Big Beautiful Bill Act, which has passed both chambers of Congress and now awaits President Trump’s signature,” said Alliance CEO Dr. Steve Landers. “These provisions—including work requirements, reduced provider taxes, and new cost-sharing mandates—prioritize short-sighted budget savings over the health and wellbeing of our most vulnerable citizens who rely on home and community-based services (HCBS).”

Dr. Steve Landers

CEO, The National Alliance for Care at Home

The Alliance Advocates for Care at Home

The home care community advocated throughout the legislative process for Congress to mitigate these harmful Medicaid provisions. The legislation will reduce state provider tax rates, cutting funding that states rely on to support HCBS programs. New work requirements and mandatory cost-sharing will also create administrative burdens for both providers and beneficiaries, likely resulting in coverage losses that extend beyond those directly targeted by these policies. Further, new limits on home equity for long-term care recipients will force older adults to sell their homes, leading to unnecessary institutionalization.

Continued Advocacy

“As these Medicaid provisions become law, the Alliance will work tirelessly to monitor their implementation and advocate for the protection of Medicaid enrollees, families, and providers nationwide,” said Dr. Landers. “We will continue to champion the delivery of HCBS – proven services that are preferred by beneficiaries and save the system money.”

Careful Consideration Needed

Landers CEO The Alliance Reconciliation Bill

The Alliance calls on federal and state officials to implement these new requirements with careful consideration of their impact on vulnerable populations and to work collaboratively with providers to minimize disruption to essential services.

# # #

About the National Alliance for Care at Home

© 2025 The National Alliance for Care at Home. This press release originally appeared on The Alliance website and is reprinted here with permission. For additional information or to request permission to print, please see the contact information above.

Follow our continuous updates on the bill passage, what it means for Medicare and Medicaid, and how the provisions of the bill will be rolled out in our accompanying article here.

CMS Home Health Proposed Rule 2026

by Kristin Rowan | Jul 2, 2025 | Advocacy, CMS, Home Health, Regulatory

by Kristin Rowan, Editor

CMS Home Health Proposed Rule 2026

June 30th, 2025, the Centers for Medicare & Medicaid Services issued its proposed rule with updates to Medicare payment policies and rates for home health agencies under the Home Health Prospective Payment System Proposed Rule for calendar year 2026.

Payment Adjustments

The Facts, as Listed by CMS

A permanent prospective adjustment to home health payments of -4.059% (not applied to LUPAs)
- Reasoning: the impact of implementing PDGM
A temporary adjustment of -5.0% (not applied to LUPAs)
- Reasoning: to recoupe retrospective overpayments
Updates Fixed-Dollar Loss (FDL) adjustment of -0.5%
Payment Update Percentage of 2.4%
Quality data decrease of 2%, offset by the update percentage yields a 0.4% adjustment
Net changes in payment rate from 2025 to 2026 with quality reporting data is -6.40%

Contradictory Facts, as Listed by CMS

The finalized methodology used to calculate the impact of PDGM yielded the need for a -7.85% permanent adjustment
In CY 2023, 2024, and 2025, CMS implemented permanent adjustments of -3.925%, -2.890%, and -1.975%, respectively
The total permanent adjustment made in the last three years is -8.790% (0.940% more than the calculated adjustment need)
CMS has now determined that Medicare is still paying more under PDGM than it did under the old system and is proposing an additional permanent adjustment of -4.059%
This yields a combined -12.849% permanent adjustment over four years
The CMS analysis of estimated aggregate expenditures lead them to propose an additional temporary adjustment of -5.0%

HHCAHPS Survey Changes

Added Questions

Whether the care provided helped the patient take care of their health.
Whether the patient’s family/friends were given sufficient information and
instructions.
Whether the patient felt the staff cared about them “as a person.”

Removed Questions - Medication

Whether someone asked to see all the prescription and over-the-counter medicines
the patient was taking.
Whether the patient is taking any new prescription medicines or whether the patient’s
medicines have changed.
Whether home health providers talked to the patient about the purpose for taking new
or changed prescription medicines.
Whether home health providers talked to the patient about when to take the
medicines.

Removed Questions - Other

Which type of staff served the patient – nurse, PT/OT, or home care aide
Whether the patient got information about what care and services they would get when they first started home health care
Removal of the proposed changes to include questions on SDOH
Minor text changes to clarfiy some existing questions and response options

Other Changes

CMS recommends additional changes in various categories:

Recalibration of the PDGM case-mix weights
- Update low utilization payment adjustment (LUPA) thresholds
- Update functional impairment levels
- Update comorbidity adjustment subgroups
- Update the fixed-dollar loss (FDL) for outlier payments
Change the face-to-face encounter policy by adding physicians to the list of who can perform the face-to-face
Removal of the “Up-to-date” on the COVID-19 vaccine percentage
Changing the Final Data Submissions Deadline Period from 4.5 months to 45 days
Adding a Termination Clause for DME, prosthetics, orthotics, and supplies competitive bidding program

Requests for Information and Feedback

CMS has issued the following RFI:

Request for Information related to Executive Order 14192 – Unleashing Prosperity Through Deregulation of the Medicare Program

CMS is seeking feedback on the proposed rule through

August 29th, 2025

Feedback on the digital quality measurement transition
Feedback on the final data submission deadline from 4.5 months to 45 days
Feedback on tools that promote healthy eating habits, exercise, nutrition, and physical activity
Feedback on the current state of health IT use, including EHRs
Feedback on the proposed changes to DMEPOS

Submit comments, feedback, and documentation to CMS

The Alliance Responds

“We are alarmed by the negligent proposed payment update, which deepens a heartless pattern of insufficient adjustments that have already led providers to close their doors and reduce services, and now threatens to further diminish care access by compelling more HHAs to take similar actions.”

Dr. Steve Landers

CEO, The National Alliance for Care at Home

You can read the entire Proposed Rule HERE. Read the Fact Sheet HERE.

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Kristin Rowan has been working at The Rowan Report since 2008. She is the owner and Editor-in-chief of The Rowan Report, the industry’s most trusted source for care at home news, and speaker on Artificial Intelligence and Lone Worker Safety and state and national conferences.

She also runs Girard Marketing Group, a multi-faceted boutique marketing firm specializing in content creation, social media management, and event marketing. Connect with Kristin directly kristin@girardmarketinggroup.com or www.girardmarketinggroup.com

©2025 by The Rowan Report, Peoria, AZ. All rights reserved. This article originally appeared in The Rowan Report. One copy may be printed for personal use: further reproduction by permission only. editor@therowanreport.com

The Alliance Responds

by Kristin Rowan | Jun 13, 2025 | Advocacy, CMS, Hospice

by Kristin Rowan, Editor

The Alliance Responds to CMS Hospice Update

The Alliance responds to CMS-1835-P, the FY 2026 Hospice Wage Index, Conditions of Participation, and Quality Reporting Program Requirements updates. On June 10, 2025, in a 25 page letter to Dr. Mehemet Oz, CEO for The National Alliance for Care at Home Steve Landers, MD, MPH lays out the constraints and financial burdens hospice agencies will face if these updates are enacted.

Payment Rate Update

Increase Less than Inflation

In the rule for FY 2026, CMS proposes a 3.2 percent market basket increase and a .8 percent productivity decrease, yielding a 2.4 percent increase overall. According to the letter, inflation has raised medical care prices by 3.1 percent, leaving a shortfall of .7 percent. Hospices are also plagued by the same workforce shortage the rest of the medical industry faces. Workforce shortages result in fewer qualified people than there are available positions, which drives wages up. BLS data indicates the wage increase for 2025 was 4.4%. The Alliance argues that the 2.4% net increase falls well short of the actual expense increase.

Faulty Data

In a recent article, we outlined the process that CMS uses to determine the market basket update. The Alliance echos our information, showing the market basket forecast is well below actual increases. The Alliance further argues that the shortfall compounds, leaving the base rate increasingly smaller with each forecast. The current estimate is a 4.9% pay rate gap. CMS contends there is no way to adjust for forecast errors. The Alliance has a simple solution: manually adjust the payment rate every year when the finalized number are above the forecasted numbers BEFORE adding the next year’s payment rate increase.

Likewise, The Alliance concurs with The Rowan Report sentiment that productivity cannot increase in hospice like it does in less labor-intensive sectors. Landers also mentions the failure to consider travel costs, the wage differences in rural areas, and the lack of reclassification options in hospice care.

Payment Rate Recommendations

As any well-drafted response should, The Alliance provides actionable recommendations in each section. For payment rate updates, The Alliance recommends:

We recommend CMS examine closely more recent data and increase final payment rates for FY 2026.
We urge CMS to explore all available avenues to address the forecast error shortfall, such as through a one-time adjustment.
We encourage CMS to collaborate with stakeholders to address the shortcomings of relying upon hospital data to determine hospice payment rates, and ways to achieve parity across provider types with respect to geographic area wage adjustments.

HIS to HOPE Transition

Also addressed in the letter is opposition to the timeline of the HIS to HOPE transition. The Alliance restates much of what was in the joint letter to CMS urging the delay of the HOPE tool adoption. That letter was a joint venture between The National Alliance for Care at Home (The Alliance), LeadingAge, and the National Partnership for Healthcare and Hospice Innovation (NPHI).

The consequence of adverse outcomes cannot be understated. The risk of negative financial consequences for hospice providers is
largely dependent this year on the success of two transitions—iQIES and HOPE— neither of which are within their control.

Steve Landers, MD, MPH

CEO, National Alliance for Care at Home

HOPE Transition Recommendations

Considering the volatility inherent in a reporting transition of this magnitude and the lack of clear information provided to date, we respectfully request CMS waive the HOPE timeliness submission requirement for two calendar quarters post implementation.
We further respectfully request that CMS delay the HOPE implementation date until at least six months after CMS education and training, beyond that which is introductory and that is scheduled for spring/summer 2025, the final validation utility tool specifications are available and the application for iQIES access has been opened for hospices.

Digital and Future Hospice Measurements

Among the digital hospice measurements is an interoperability measurement. The Alliance supports interoperability and data exchange across medical care entities, but stresses to CMS that many hospices do not have digital EHR systems, cannot afford to maintain such systems, and have not received the federal financial support necessary to meet this objective.

The Alliance also objects, not in theory, but in practical application, to the nutrition measure noted in future hospice measures. Nutrition for a hospice patient is vastly different than for other patients and should be implemented as a process measure, rather than having specific goals for food intake and nutrition.

Similarly, the well-being measure is not designed for hospice care. In other sectors of healthcare, well-being incorporates measures for mental, social and physical health and focuses on curative plans. Hospice care focuses on person-centered care, emphasizing the desires of the patient as they are balanced against religious, cultural, and personal beliefs. The well-being measure must be curated to fit hospice care.

The Alliance - Conclusion

The Alliance values CMS’s ongoing commitment to enhancing hospice care quality,
ensuring program integrity, and improving patient outcomes. We appreciate your
consideration of our comments and look forward to ongoing dialogue to achieve these
shared objectives.

The Rowan Report - Conclusion

The Alliance has, as always, done an exemplary job at explaining the industry position on the CMS rule. Likewise, it has outlined each step CMS should take to view the updates through a hospice lens rather than a hospital lens. We commend and support The Alliance statement and position. As this is an ongoing topic until the final rule is implemented, we will continue to provide updates as they become available.

If you are a member of The Alliance, you can read the full 25 page letter here.

# # #

Delay HOPE Tool

by Kristin Rowan | Jun 6, 2025 | Advocacy, CMS, Hospice, Regulatory

by Kristin Rowan, Editor

Advocacy Groups to CMS:

Delay HOPE Tool Implementation

“Delay HOPE Tool Implementation,” say multiple hospice advocacy groups. LeadingAge, the National Alliance for Care at Home (The Alliance), and the National Partnership for Healthcare and Hospice Innovation (NPHI) are urging CMS to delay the transition from HIS to HOPE. The three groups sent a joint letter to Dr. Mehmet Oz, CMS Administrator, earlier this week.

“Our associations remain fully committed to the [Hospice Quality Reporting Program (HQRP)], including the payment penalties for non-compliance, and recognize the critical importance of accurate, timely data submission to inform the delivery of high-quality hospice care. However, we have serious concerns about the potential for successful implementation of the HOPE tool.”

LeadingAge, The Alliance, NPHI

Hospice Advocacy

The concerns over agency readiness to implement the new tool center on the new reporting platform. Hospice agencies state they don’t have all the necessary information to develop a workable tool for submission. Therefore, the agencies have asked CMS to delay the implementation of the HOPE tool. They have called on CMS to wait until six months after agencies have access to education, training, and final validation specifications.

Hospice Rule Penalty

The hospice program through CMS requires substantial reporting for payment. Hospices that do not submit the required 90% of records, they receive an annual payment penalty of 4%. Combined with lower than sustainable payment increases, the 4% penalty results in a lower reimbursement rate over prior years. The associations worry that the lack of information and education will lead to lower reporting. In turn, the lower reporting lowers reimbursement rates. For hospices that are already struggling to survive, the penalty is devastating. The letter to CMS asked to waive the timeliness requirement for two quarters after implementation.

HOPE Tool Lacks Validation

CMS will have a Validation Utility Tool that agencies will need to use in order to ensure their software can successfully submit their data. CMS has not released the tool and indicates they may not until sometime in September. The HOPE tool is scheduled for implementation in October. There is not enough time between release of the validity tool and implementation of the HOPE tool for proper testing.

Hospice Agencies Lack Validation

In addition to validating data submission, hospice agencies have to enroll in the new submission portal, iQUIES. Enrollment requires a privacy security official and other staff. Additionally, it requires an application to access the system, background checks, and other actions. Thus far, hospice agencies do not have access to begin this process and there is no indication of how long it will take. The associations are concerned that the process may also involve significant financial cost to hospice agencies.

Resources

CMS released the Hospice Outcomes and Patient Evaluation (HOPE) Guidance Manual v1.01, a 138 page PDF, available here. The manual includes links to other resources for hospice agencies. Namely, a webpage with information on HOPE Data Submission Specifications has a “final” version of data specs available for download. Additionally, there are links to the Main Page here and technical information and updates here. The document urges vendors to register to get updates and important announcements.

Final Thoughts

There is no information yet as to a response to the letter from CMS. Thus far, CMS is still planning on keeping the October 1, 2025 HOPE implementation date. We will continue to report on updates from CMS and the advocacy groups.

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Industry Update

by Kristin Rowan | Apr 24, 2025 | Admin, Advocacy, Medicaid, Medicare, Medicare Advantage, Regulatory

by Kristin Rowan, Editor

Industry Update with Dr. Steve Landers

At last week’s New England Home Care & Hospice Conference, Dr. Steve Landers, President of The National Alliance for Care at Home (The Alliance) gave the keynote address and offered some industry insights and updates.

A Heartfelt Introduction

Ken Albert, Chairman of the Board at The Alliance introduced Dr. Landers before his address. After reading Dr. Landers’s official biography, Albert offered his own thoughts on the first few months of Landers’ tenure.

Last year, five colleagues from organizations across the country sat in D.C. interviewing candidates. While interviewing Landers, I was remarkably engaged by someone who is deeply passionate about care at home. Steve describes hospice care as a national treasure, and I don’t disagree. More than just his passion for care at home, Dr. Landers is savvy in navigating the political paradigms driving policy. He artfully combines data and stories to navigate relationships with policy makers. What I see every day is someone who roles up his sleeves for the patients we take care of with tremendous respect for the caregivers who are in the patients’ homes.

Ken Albert

Chairman of the Board, The National Alliance for Care at Home

Industry Changes, Advancements, and Ongoing Advocacy Efforts

Dr. Landers attributes much of the positive changes in D.C. to the efforts of volunteer leaders looking to move the industry forward. Care at home needs to become more streamlined, more efficient, and with a better voice.

His vision for the care at home industry is an America where everyone can access high-quality care wherever they call home.

Strong Admonition for CMS

Dr. Landers noted positive movement in some areas. However, he became passionately adamant that a payment update is not an increase if it doesn’t keep up with inflation or pay increases. “The Alliance represents providers delivering high-quality, person-centered care to million of individuals in the home, and they deserve to be recognized and compensated for the work they do,” he said.

Our Aging Nation

It should come as no surprise that older adults have a strong preference for aging at home. They prioritize living where they feel in control and connected. They want to be in familiar surroundings and to maintain their routines.

The U.S. population over the age of 85 is expected to triple from 2020-2060 to more than 19 million people. Despite medical advances, only 1/3 of those over the age of 85 say they are free of disability or free of difficulty with daily living.

With the rising number of older individuals, caregiver to patient ratios are falling nearly everywhere across the country. Dr. Landers and The Alliance urge policymakers to make promoting the dignity and independence of our aging population one of their highest health policy priorities. The Alliance will continue to tell anyone and everyone who will listen that care at home offers the win-win solution that policymakers are looking for.

Changes at the Top

We’ve already seen numerous and sometimes drastic changes at the federal level. Dr. Landers points out that eight years ago the “Trump 1.0 Administration” developed the PDGM framework and signed hospice reform legislation. On the campaign trail, President Trump stated he would not be making cuts to Medicare. The “Trump 2.0” care at home priorities are not yet clear, but The Alliance will continue to emphasize cost savings and the preference to age in place.

Secretary Kennedy, head of HHS, placed his emphasis on the chronic disease epidemic, launching Making America Healthy Again. He has stated a preference for community-based solutions and patient-centered care.

New CMS Administrator Dr. Oz seems to be supportive of Medicare Advantage, but did have some critique of the program during senate hearings. Dr. Oz has a stated focus of finding and eliminating fraud, waste, and abuse.

Changes Near the Top

At the congressional level, The Alliance lost a few key supporters with the last election, but many care at home advocates remained. Of the returning members of the Senate and House, care at home advocates include:

Senators Collins (R-ME), Hassan (D-NH), Tillis (R-NC), Barrasso (R-WY), Blackburn (R-TN), CortezMasto (D-NV), and Rosen (D-NV)
Representatives: Adrian Smith (R-NE), Sewell (D-AL) Van Duyne (R-TX), Panetta (D-CA), Guthrie (RKY), and Carter (R-GA)

The support in Congress leaves us hopeful. Large Reconciliation Packages dominate the current conversation. Many questions remain as to what is at risk for care at home and what Medicaid’s future might hold.

Later this year, The Alliance sees opportunities for care at home outside of reconciliation. These include Home Health PDGM reform, hospice reform, the telehealth extension, revocation of the Medicaid HCBS 80/20 rule, tax credits, and long term care insurance.

Public Policy Priorities

As The Alliance moves forward, several key issues will remain priorities:

Access to Care at Home

PDGM Implementation
Telehealth Extension
Medicare Advantage Dynamics
Care for High Needs Beneficiaries

Quality Care at Home

Special Focus Program Implementation
DEA Telehealth Provisions
HOPE tool implementation?

Eliminating Fraud and Abuse in Care at Home

Hospice Concurrent Care
Hospice and Medicare Advantage
Medicaid 80/20 Rule
Caregiver Tax Credits / LTCI

Growing the Care at Home Workforce

Supply is simply not meeting demand
Strengthened rates, incentives, and educational opportunities will attract and retain a qualified workforce

Follow Up

I spoke with Dr. Landers after the keynote address to ask him why lone worker safety was not among the top priorities of The Alliance. He assured me that there is a position within The Alliance who, among other tasks, is focusing on lone worker safety. I urged him to make it a higher priority and will follow up to get the contact information for the position he mentioned.

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MedPAC Comments on CY 2026

by Kristin Rowan | Mar 22, 2025 | CMS, Editorial, Medicare Advantage, Regulatory

by Kristin Rowan, Editor

MedPAC Comments on CY 2026

MedPac Sends Recommendations to Congress

MedPAC makes recommendations to Congress and HHS on issues affecting the Medicare program. The March report for 2025 includes recommendations for hospice, home health, and SNFs, in addition to in-patient and out-patient hospital services.

Hospice

Using the exact terminology from the 2024 report, MedPAC recommends that Congress eliminate the update to the 2025 Medicare base payment rates for hospice. MedPAC pointed to a number of statistics to support the evaluation:

The number of hospice providers increased in 2023
Some of the growth in hospice providers occurred in states where CMS has concerns over program integrity
The percentage of patients using hospice increased by .8 percent nationwide, as did the days of care and visits per week
Medicare payments exceeded marginal costs by 14 percent

Opinion

The population of the U.S. is aging as more and more Baby Boomers qualify for Medicare; there is an increased need for hospice agencies to accommodate the volume of patients
Whether there are more hospices in states where program integrity is questioned does not impact the need for hospice care; program integrity reform changes this, not reimbursement rates
The rise in use, length of stay, and days of care explain the increase in the number of hospice; need, not profitability drives this growth
The average markup in 2022 was 72 percent above marginal cost

Marginal Cost

Marginal cost is the cost of adding one more unit of production. In simple terms, that would be the overall costs of adding one hour of care for a hospice patient. This would include scheduling, hourly wage, and other operational costs. MedPAC believes that if an agency adds one hour of care and make 14 percent more than their costs, that is sufficient.

Home Health

Keeping with tradition, MedPAC used the same language again from 2024 to recommend that Congress reduce the 205 Medicare base payment rate for home health agencies by 7 percent.

The number of HHAs participating in Medicare increased by 3.4 percent.
Most of the growth in HHAs was in LA County. Outside LA County, the number of HHAs decreased by 2.8 percent.
The number of 30-day episodes per beneficiary decreased by 1.8 percent, but is still higher than in prepandemic years
MedPAC was unable to compute the marginal profit for 2023
Quality of care (percent discharged to community) increased by 1.3 percent
The all-payer margin in HHAs was 8.2 percent, attracting investors
The projected Medicare payment margin for 2025 is 19 percent

Image of letters spelling health and wealth

Opinion

LA County has more HHAs, but the rest of the country has fewer. We believe if you ask The National Alliance for Care at Home, Bill Dombi, or any number of prior HHA owners, low reimbursement rates forced them out of business

Pandemic numbers skewed the need for care at home because everyone was at home; if you only look at prepandemic numbers compared with 2023 numbers, the need for home health is increasing
HHAs keep patients out of the hospital, which accounts for more Medicare payments and higher costs
Again, the average margin across the U.S. is 72 percent, but MedPAC somehow believes 8 percent will attract investors and buyers; volume is attracting buyers, not margins
The projected 2025 margin is 19 percent and MedPAC recommends lowering it to 14 percent, matching hospice, and is 58 percent lower margins than the average industry

One Point of Parity

Surprisingly, there is an overlap in thinking between providers and MedPAC. In the February 2025 comment on the CMS notice of proposed rulemaking for 2026, MedPAC addressed the coding intensity and increased Medicare Advantage payments.

Last summer, Editor Emeritus Tim Rowan reported on the inflated health conditions filed by payers. Medicare Advantage payers also routinely deny care that traditional Medicare plans would cover. MA payers are collecting on both the front and back ends of the “Bank of CMS.” According to the Center for Economic Policy Research, upcoding by MA plans costs CMS 106 percent of traditional Medicare costs. Quality bonus payments add an additional 2 percent. Operating surplus from enrolling healthier beneficiaries adds another 11 percent. Payments to MA plans are 19 percent higher. MedPAC agrees and urges CMS to further investigate coding intensity from MA payers.

Point of Contention

Although we agree with MedPAC’s assessment of MA coding intensity, that is where the similarity ends. Let’s take that recommendation one step further and require that MA plans pay hospice and home health providers a higher percentage of their risk-assessment adjustment and let the payers make their profits elsewhere.

It Could be Worse

Given the recent upheaval in D.C. and the fear that Medicare, Medicare Advantage, Medicaid, Social Security, and other benefits would be done away with completely, we are relieved to see the House Budget Bill passing without the drastic reductions to care at home.

From the Alliance

Following the passing of the House Budget Bill, The National Alliance for Care at Home issued a response statement. We’ve published the full response here for you.

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Kristin Rowan has been working at The Rowan Report since 2008. She is the owner and Editor-in-chief of The Rowan Report, the industry’s most trusted source for care at home news. She also has a master’s degree in business administration and marketing and runs Girard Marketing Group, a multi-faceted boutique marketing firm specializing in content creation, social media management, and event marketing. Connect with Kristin directly kristin@girardmarketinggroup.com or www.girardmarketinggroup.com

Alliance Statement on Congressional Budget

by Rowan Report | Mar 21, 2025 | Advocacy, CMS, Partner News, Regulatory

FOR IMMEDIATE RELEASE

Contacts: Tom Threlkeld
202-547-7424
Email

Elyssa Katz
571-281-0220
Email

The Alliance Comments on Recent Congressional Budget and Reconciliation Activity

ALEXANDRIA, VA and WASHINGTON, DC, March 5, 2025 – The National Alliance for Care at Home (the Alliance) released the following statement regarding recent legislative developments that may impact the Medicaid program. These include the passage of the House Budget Bill and the reconciliation framework that includes instructions for the House Energy and Commerce Committee to find $880 billion in reductions to programs under its jurisdiction; passage of the Senate Budget framework that does not include such drastic reductions; and comments by Speaker of the House Johnson (R-LA) that any changes to Medicaid will not include caps on federal funding or changes to the state matching formulas.

“The Alliance is reassured by affirmations that the congressional majority will not pursue some of the most drastic proposals previously discussed as options for reducing federal expenditures. Our members will not support any policies that reduce access to essential home and community-based services for eligible individuals. As Congress continues to assess options to reduce federal spending, we encourage leaders to continue to look favorably on high-value services that reduce costs and improve participant satisfaction.

“Care in the home is a proven model that reduces costs and is preferred by patients and families. An independent evaluation of Money Follows the Person, a grant program that transitioned individuals from institutional settings to the community, found that total spending on older adults decreased by 20 percent during the first year and 27 percent during the second year following their move to the community.[1] If Congress wishes to seek opportunities to reduce spending, we recommend they advance care models that provide cost-effective care without limiting access to services.

“We also recognize that there are opportunities to strengthen program integrity and reduce instances of fraud, waste, and abuse in the health care sector. The Alliance supports actions that reduce fraud, waste, and abuse from bad actors without placing unnecessary burdens or unfairly punishing providers and beneficiaries who are acting in good faith. We look forward to working with Congress to advance policies that strengthen federal health care program oversight.

“Medicaid is a complex program and changes to one part of the statute may have unanticipated negative outcomes on other aspects of services, financing, or reimbursements. We encourage Congress to be extremely careful to avoid making changes that could lead to unintended outcomes. We stand ready to provide our expertise to help strengthen Medicaid for all individuals and providers.”

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About the National Alliance for Care at Home

The National Alliance for Care at Home (the Alliance) is a new national organization representing providers of home care, home health, hospice, palliative care, and other health care services mainly delivered in the home. The Alliance brings together two organizations with nearly 90 years of combined experience: NAHC and NHPCO. NAHC and NHPCO have combined operations to better serve members and lead into the future of care offered in the home. Learn more at www.AllianceForCareAtHome.org.   

[1] https://www.medicaid.gov/medicaid/long-term-services-supports/downloads/mfpfieldreport21.pdf

Here We Go Again

by Tim Rowan | Nov 8, 2024 | Clinical, CMS, Editorial, Medicare Advantage, Regulatory

by Tim Rowan, Editor Emeritus

OIG Accuses Medicare Advantage Providers of Padding Patient Assessments...Again

“Hello, this is your Medicare Advantage company calling. I am one of their clinicians and it is time for us to update your health assessment. If you will agree to a home visit, we will send you a $50 gift card to CVS.”

This phone call my brother received is typical, increasingly common, and not necessarily on the up-and-up, according to a new report to CMS from the Department of Health and Human Services Office of the Inspector General (OIG). OIG found that these home visits, known in the insurance industry as “Health Risk Assessments,” (HRA) when coupled with HRA-related claims data, increased Medicare Trust Fund payments to MA companies $7.5 billion in 2022 and twice that in 2023. Most of it went to the top 20 companies.

The October 2024 report, “Medicare Advantage: Questionable Use of Health Risk Assessments Continues to Drive Up Payments to Plans by Billions,” accuses the industry as a whole of improperly padding payments by “finding” new health conditions during these HRA’s that may indicate the need for additional care at additional cost to the company. It questions the use of MA plan employees doing these assessments instead of relying on the customer’s primary care physician’s reports.

OIG references CMS’s own report, “Part C Improper Payment Measure (Part C IPM) Fiscal Year 2023 (FY 2023) Payment Error Rate Results,” to determine that gross overpayments to Medicare Part C plans in 2023 amounted to just over six percent of total payments, or $14.6 billion. The net increase to MA plans, after adjusting for underpayments, brought the percentage to 4.62. Total 2023 payments to MA plans came to $275,605,962,817.

The report also points out that identifying additional customer need during an HRA does not necessarily translate into the insurance company paying for additional care.

OIG Recommendations

In addition to implementing prior OIG recommendations, the new report asks CMS to:

- Impose additional restrictions on the use of diagnoses reported only on in-home HRAs or chart reviews that are linked to in-home HRAs for risk-adjusted payments,
- Conduct audits to validate diagnoses reported only on in-home HRAs and HRA-linked chart reviews, and
- Determine whether select health conditions that drove payments from in-home HRAs and HRA-linked chart reviews may be more susceptible to misuse among MA companies.

CMS concurred with OIG’s third recommendation but rejected the other two.

While the entire 38-page report is well-worth reading, OIG has also published a one-page summary.

At this year’s annual conference of The National Alliance for Care at Home, the new merger of NAHC and NHPCO, a number of education sessions were devoted to teaching Home Health agency owners how to negotiate with Medicare Advantage plans in order to minimize losses and better care for patients who chose those plans. Comments included the high rate of care denial, unreasonable prior authorization policies, and slow payments as compared to traditional Medicare. Other healthcare entities have chosen a potentially more effective response: Just Say No.

Hospital systems have had enough

According to a roundup of recent decisions by large and small healthcare systems in Becker’s Hospital CFO Report (10/25/24), no fewer than 30 healthcare providers are severing their relationships with one or more MA plans, with another 60 who told Beckers they are seriously considering the same move.

States Have as Well

A sister publication, Becker’s Payer Issues, reported in its October 23 edition that more and more states are issuing fines against MA plans for violations ranging from excessive denied claims to collection of co-pays when none was required.

How Much Longer?

All of this demands a serious question. How much longer will Home Health continue to tolerate abuse by these giant, for-profit payers now that a different path forward has been paved by hospital systems and state regulatory arms? The loudest voice for Home Health to join the “Just Say No” movement over the last few years has been that of Bruce Greenstein, CTO of LHC Group. Following his company’s acquisition by UnitedHealth’s Medicare Advantage division, Optum, his less loud message is to work with MA plans to teach them what Home Health is and what it can do for them.

Statement from Dr. Landers

In his inaugural address to The Alliance last month, new CEO Dr. Steven Landers called for our entire industry and everyone taking a paycheck from it to join him in advocacy. We fully support that call to action, recognizing that no national association can influence lawmakers and CMS regulators without member support, but he was referring to Medicare rules and payment structures. As we know, that includes less than half of Medicare beneficiaries today. Thanks to deceptive TV ads during open enrollment every year, that number will continue to shrink.

Widespread Advocacy

We need to turn at least part of our advocacy focus to the dominant payers, the MA divisions of insurance companies. Read the Beckers report on the 30 healthcare systems that have torn up their MA contracts. Read the companion report about the epidemic of care denials. Yes, it is a David vs. Goliath story, with even the largest organizations in Home Health dwarfed by the size of the payers. As so many hospital systems have shown, however, it is possible to switch from begging for a few more cents per visit to forcing a plan to beg you to take their patients.

It will only work though if everyone does it. We have already lost LHC Group, and Optum is in the final stages of adding Amedisys to their stable. Out of 11,000 HHAs, there is still a chance we have a united voice loud enough to be heard and taken seriously.

Final Thoughts

One of their improper cost-cutting tactics is routine care denial. For example, the Labor Department alleged that UnitedHealth subsidiary UMR denied all urine drug screen claims from August 2015 to August 2018 without determining whether a claim was medically necessary. In my brother’s case, following his wife’s HRA by her MA company, with no additional care offered, he made the tough choice to put her on in-home hospice care. The assessing nurse immediately detected she had a UTI and ordered the appropriate antibiotics. She responded quickly and may be discharged from hospice soon. Hospice care, of course, is paid by traditional Medicare, not Medicare Advantage.

Tim Rowan is a 30-year home care technology consultant who co-founded and served as Editor and principal writer of this publication for 25 years. He continues to occasionally contribute news and analysis articles under The Rowan Report’s new ownership. He also continues to work part-time as a Home Care recruiting and retention consultant. More information: RowanResources.com or contact Tim at Tim@RowanResources.com

©2024 by The Rowan Report, Peoria, AZ. All rights reserved. This article originally appeared in Healthcare at Home: The Rowan Report.homecaretechreport.com One copy may be printed for personal use: further reproduction by permission only. editor@homecaretechreport.com

An Interview with Dr. Steven Landers, Part 2

by Kristin Rowan | Oct 25, 2024 | Advocacy, CMS, Medicare Advantage, Regulatory

by Kristin Rowan, Editor

Medicare Advantage is Killing Us...Literally

This is part 2 of 2 in the interview with Dr. Steven Landers. You can read part 1 here.

Medicare Advantage article by Dr. Landers

Earlier this week, Dr. Landers published an article in the NAHC Report. The article cited three studies and analyses on the number of enrollees in both Medicare and Medicare Advantage who do not receive the care to which they are entitled. During our recent interview with Dr. Landers, he addressed this article.

Dr. Steven Landers: On the Record

The Rowan Report:

You wanted to address something you recently wrote. Is this the same topic you mentioned the opening session, or is this something else?

Dr. Steven Landers:

No, this is a focused piece on the emerging research that we’re seeing around when people miss out on home health. It’s a life and death issue. I want to be sure that we, as an alliance, I, as a physician, and us, as advocates, that we are conveying that these issues around home health cuts and barriers are potentially deadly. This is not a trivial matter. It’s not an administrative or technical financial issue. It’s about people’s lives.

RR:

The article mentioned a study that said that the numper of people not getting the home care that they’re entitled to is almost double with Medicare Advantage enrollees over traditional Medicare.

Steve:

That was from a study that’s referenced there from a few years ago. The Partnership for Quality Home Health Arcadia Analysis that came out this year actually showed that those trends are worsening. We know that they’re not getting the needed care in Medicare Advantage and traditional Medicare.

In both cases it’s too high, but it’s higher in Medicare Advantage. It’s more common that people don’t get the prescribed care in Medicare Advantage. And we also know that that’s going up in both traditional Medicare and Medicare Advantage. The access has gotten worse because of the Medicare home health policy and because of the way that Medicare Advantage has grown and handled these issues.

Interviewer:

I guess the big giant question is what do we do, especially when margins for both traditional Medicare and Medicare Advantage are so low?

Steve:

One, we’ve got to start improving access to home healthcare. And the way that we do that is we end this march of payment cuts that are being set forward by Medicare. I mean, right now the leaders of Medicare are in their rulemaking process and they have choices to make. They can either do things that reverse this trend and put us on a path to better access or I think continuing these cuts will hurt beneficiaries.

And the other piece is the Medicare advantage front. We need more scrutiny and evaluation and potentially oversight here to make sure Medicare Advantage beneficiaries have access to high quality home healthcare.

“The results of this study demonstrate that among MA members referred to home health after acute hospitalization, those who did not receive home health services experienced higher mortality and lower readmissions than those who received these services.”

Unfulfilled Home Health Referrals Lead to Higher Mortality Among Medicare Advantage Members

Elan Gada, MD, Paul Pangburn, MHA, Chris Sahr, MS, MBA, Chad P. Schaben, MPH, Richard Young, MS

RR:

Where does the problem lie?

Steve:

People don’t get home health when it’s prescribed and mortality rates are substantially higher. There could be [anecdotal] reasons that this is happening. I’ve tried to think of them. I can’t really come up with them when you see it in three different analyses, especially one done within the Medicare Advantage plan. They have great data. It was well thought out and this is serious business and it really should be a kitchen table discussion for families like ‘what’s going here?,’ because obviously home healthcare is a beloved service that families care deeply about.

We’ve seen home care become a presidential campaign issue because it’s good policy and also because the folks running, Vice President Harris, who brought it up, and former President Trump, who chimed in sort of a me too, being enthusiastic about the concept. They’ve got to know that this polls well, that the families care about this stuff.

Editor Emeritus Tim Rowan provides an analysis of the study from UnitedHealth Group here.

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Kristin Rowan has been working at Healthcare at Home: The Rowan Report since 2008. She has a master’s degree in business administration and marketing and runs Girard Marketing Group, a multi-faceted boutique marketing firm specializing in event planning, sales, and marketing strategy. She has recently taken on the role of Editor of The Rowan Report and will add her voice to current Home Care topics as well as marketing tips for home care agencies. Connect with Kristin directly kristin@girardmarketinggroup.com or www.girardmarketinggroup.com

©2024 by The Rowan Report, Peoria, AZ. All rights reserved. This article originally appeared in Healthcare at Home: The Rowan Report. One copy may be printed for personal use: further reproduction by permission only. editor@therowanreport.com

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